Firm profile

Two Sigma Investments, LP

NEW YORK, NYCRD 137137Registration Status: ApprovedEffective since August 21, 2009SEC # 801-70476Latest ADV March 31, 2026

Two Sigma Investments, LP is an SEC registered investment adviser organized as a limited partnership with a primary office location in New York, NY. Its latest Form ADV filing, dated March 31, 2026, reports $232.8B in regulatory assets under management, 1,555 employees, 3 offices, and 42 accounts.

Assets Under Management
$232.8B
Employees
1,555
Offices
3 offices
Total Clients
42

Associated firm names

2 names listed
  • TWO SIGMA INVESTMENTS, LLC
  • TWO SIGMA INVESTMENTS, LP

Leadership

6 roles identified
CEOCarter M. Lyons
CCOJames G. Hein Jr.
CFODawn M. Schoppner

Advisory services offered

3 types reported
Portfolio management for businesses
Portfolio management for investment companies
Portfolio management for pooled investment vehicles

Fee models offered

2 types reported
Asset based fees
Performance-based fees

Offices & Contact

Primary office

NEW YORK, New York, United States

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Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

New York

NEW YORKPrimary office

Florida

PALM BEACH GARDENS

3 office records listed · 3 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$232.8Bas of March 31, 2026
Discretionary100.0%
$232.8B
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentPooled Investment Vehicles represent 92.9% of total clients.
Top client categories% of clientsClients
1
Pooled Investment Vehicles
92.9%
39
2
Investment Cos.
2.4%
1
3
Sovereign Wealth
2.4%
1
4
Corporations
2.4%
1
Categories with <5 clients
Corporations or other businesses not listed above<5 clients
Sovereign wealth funds and foreign official institutions<5 clients

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$232.8B
Total Accounts42
10Y AUM Change+$183.6B (+372.5%)

Private Funds

Private funds reported by Two Sigma Investments, LP

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Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees1,555
Clients per Employee0:1
10Y Employee Change+480 (+44.7%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.


Ownership

Reported direct and indirect ownership ranges

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
JOHN A. OVERDECK REVOCABLE TRUSTDirect owner · Schedule AInterest in TWO SIGMA INVESTMENTS, LP
25% to < 50%
DAVID M. SIEGEL REVOCABLE TRUSTDirect owner · Schedule AInterest in TWO SIGMA INVESTMENTS, LP
25% to < 50%
JOHN ALBERT OVERDECKDirect owner · Schedule AInterest in TWO SIGMA INVESTMENTS, LP
25% to < 50%
DAVID MARK SIEGELDirect owner · Schedule AInterest in TWO SIGMA INVESTMENTS, LP
25% to < 50%
SUNBURST TRUSTDirect owner · Schedule AInterest in TWO SIGMA INVESTMENTS, LP
5% to < 10%
SUDACHI CONTINUATION TRUSTDirect owner · Schedule AInterest in TWO SIGMA INVESTMENTS, LP
5% to < 10%
SUNFLOWER PTC LLCDirect owner · Schedule AInterest in TWO SIGMA INVESTMENTS, LP
5% to < 10%
SHINRAI PTC LLCDirect owner · Schedule AInterest in TWO SIGMA INVESTMENTS, LP
5% to < 10%
TWO SIGMA MANAGEMENT, LLCDirect owner · Schedule AInterest in TWO SIGMA INVESTMENTS, LP
< 5%
THOMAS GERARD RAFFERTYDirect owner · Schedule AInterest in TWO SIGMA INVESTMENTS, LP
< 5%
SUNFLOWER SPECIAL PURPOSE TRUST IIndirect owner · Schedule BInterest in SUNFLOWER PTC LLC
75%+
SHINRAI SPECIAL PURPOSE TRUST IIndirect owner · Schedule BInterest in SHINRAI PTC LLC
75%+
JOHN A. OVERDECK REVOCABLE TRUSTIndirect owner · Schedule BInterest in TWO SIGMA MANAGEMENT, LLC
25% to < 50%
DAVID M. SIEGEL REVOCABLE TRUSTIndirect owner · Schedule BInterest in TWO SIGMA MANAGEMENT, LLC
25% to < 50%

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Two Sigma Investments, LP.

Reported ownership and control details

Form ADV · Filing date 2026-03-31 · Schedules A and B

35 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1JOHN ALBERT OVERDECKCO-CHAIRMAN, TWO SIGMA MANAGEMENT, LLC; EXECUTIVE MANAGER, TWO SIGMA MANAGEMENT, LLCIndividualTWO SIGMA INVESTMENTS, LPLess than 5%Code NAYesCO-CHAIRMAN, TWO SIGMA MANAGEMENT, LLC; EXECUTIVE MANAGER, TWO SIGMA MANAGEMENT, LLC05/2001Schedule APDF page 545
2DAVID MARK SIEGELCO-CHAIRMAN, TWO SIGMA MANAGEMENT, LLCIndividualTWO SIGMA INVESTMENTS, LPLess than 5%Code NAYesCO-CHAIRMAN, TWO SIGMA MANAGEMENT, LLC07/2001Schedule APDF page 545
3TWO SIGMA MANAGEMENT, LLCGENERAL PARTNERDomestic entityTWO SIGMA INVESTMENTS, LPLess than 5%Code NAYesGENERAL PARTNER12/2005Schedule APDF page 545
4DAWN MARIE SCHOPPNERCHIEF FINANCIAL OFFICERIndividualTWO SIGMA INVESTMENTS, LPLess than 5%Code NANoCHIEF FINANCIAL OFFICER09/2010Schedule APDF page 545
5JOHN A. OVERDECK REVOCABLE TRUSTLIMITED PARTNERDomestic entityTWO SIGMA INVESTMENTS, LP25% to less than 50%Code CYesLIMITED PARTNER01/2008Schedule APDF page 545
6DAVID M. SIEGEL REVOCABLE TRUSTLIMITED PARTNERDomestic entityTWO SIGMA INVESTMENTS, LP25% to less than 50%Code CYesLIMITED PARTNER01/2008Schedule APDF page 545
7JOHN ALBERT OVERDECKTRUSTEE OF JOHN A. OVERDECK REVOCABLE TRUSTIndividualTWO SIGMA INVESTMENTS, LP25% to less than 50%Code CYesTRUSTEE OF JOHN A. OVERDECK REVOCABLE TRUST12/2007Schedule APDF page 545
8DAVID MARK SIEGELTRUSTEE OF DAVID M. SIEGEL REVOCABLE TRUSTIndividualTWO SIGMA INVESTMENTS, LP25% to less than 50%Code CYesTRUSTEE OF DAVID M. SIEGEL REVOCABLE TRUST12/2007Schedule APDF page 545
9SUNBURST TRUSTLIMITED PARTNERDomestic entityTWO SIGMA INVESTMENTS, LP5% to less than 10%Code ANoLIMITED PARTNER01/2020Schedule APDF page 545
10SUDACHI CONTINUATION TRUSTLIMITED PARTNERDomestic entityTWO SIGMA INVESTMENTS, LP5% to less than 10%Code ANoLIMITED PARTNER12/2025Schedule APDF page 545
11SUNFLOWER PTC LLCTRUSTEE OF SUNBURST TRUSTDomestic entityTWO SIGMA INVESTMENTS, LP5% to less than 10%Code ANoTRUSTEE OF SUNBURST TRUST01/2020Schedule APDF page 545
12SHINRAI PTC LLCTRUSTEE OF SUDACHI CONTINUATION TRUSTDomestic entityTWO SIGMA INVESTMENTS, LP5% to less than 10%Code ANoTRUSTEE OF SUDACHI CONTINUATION TRUST12/2025Schedule APDF page 545
13CARTER MAYBERRY LYONSCO-CHIEF EXECUTIVE OFFICERIndividualTWO SIGMA INVESTMENTS, LPLess than 5%Code NAYesCO-CHIEF EXECUTIVE OFFICER02/2020Schedule APDF page 545
14STEVE HAMILTON METZGERGENERAL COUNSELIndividualTWO SIGMA INVESTMENTS, LPLess than 5%Code NANoGENERAL COUNSEL07/2023Schedule APDF page 545
15TIMOTHY JOHN REYNOLDSCHIEF OPERATING OFFICERIndividualTWO SIGMA INVESTMENTS, LPLess than 5%Code NANoCHIEF OPERATING OFFICER07/2023Schedule APDF page 545
16JAMES GERARD HEIN JR.CHIEF COMPLIANCE OFFICERIndividualTWO SIGMA INVESTMENTS, LPLess than 5%Code NANoCHIEF COMPLIANCE OFFICER07/2025Schedule APDF page 545
17CHRISTOPHER PAUL SALESCO-CHIEF INVESTMENT OFFICERIndividualTWO SIGMA INVESTMENTS, LPLess than 5%Code NANoCO-CHIEF INVESTMENT OFFICER07/2025Schedule APDF page 545
18GEOFFREY P DUNCOMBECO-CHIEF INVESTMENT OFFICERIndividualTWO SIGMA INVESTMENTS, LPLess than 5%Code NANoCO-CHIEF INVESTMENT OFFICER01/2026Schedule APDF page 545
19SETH PHILLIP PLATTEXECUTIVE MANAGER, TWO SIGMA MANAGEMENT, LLCIndividualTWO SIGMA INVESTMENTS, LPLess than 5%Code NAYesEXECUTIVE MANAGER, TWO SIGMA MANAGEMENT, LLC03/2026Schedule APDF page 545
20THOMAS GERARD RAFFERTYTRUSTEE OF DAVID M. SIEGEL REVOCABLE TRUSTIndividualTWO SIGMA INVESTMENTS, LPLess than 5%Code NANoTRUSTEE OF DAVID M. SIEGEL REVOCABLE TRUST02/2026Schedule APDF page 546
21JOHN A. OVERDECK REVOCABLE TRUSTMEMBERDomestic entityTWO SIGMA MANAGEMENT, LLC25% to less than 50%Code CYesMEMBER01/2008Schedule BPDF page 546
22DAVID M. SIEGEL REVOCABLE TRUSTMEMBERDomestic entityTWO SIGMA MANAGEMENT, LLC25% to less than 50%Code CYesMEMBER01/2008Schedule BPDF page 546
23JOHN ALBERT OVERDECKTRUSTEEIndividualJOHN A. OVERDECK REVOCABLE TRUSTPercentage not specifiedCode FYesTRUSTEE12/2007Schedule BPDF page 546
24DAVID MARK SIEGELTRUSTEEIndividualDAVID M. SIEGEL REVOCABLE TRUSTPercentage not specifiedCode FYesTRUSTEE12/2007Schedule BPDF page 546
25SUNFLOWER SPECIAL PURPOSE TRUST IMEMBERDomestic entitySUNFLOWER PTC LLC75% or moreCode ENoMEMBER01/2020Schedule BPDF page 546
26FRONTIER DIRECTED FIDUCIARY SERVICES LLCTRUSTEEDomestic entitySUNFLOWER SPECIAL PURPOSE TRUST IPercentage not specifiedCode FNoTRUSTEE01/2020Schedule BPDF page 546
27SUNFLOWER SPECIAL PURPOSE TRUST IIMANAGERDomestic entitySUNFLOWER PTC LLCPercentage not specifiedCode FNoMANAGER01/2020Schedule BPDF page 546
28SHINRAI PTC LLCTRUSTEEDomestic entitySUDACHI CONTINUATION TRUSTPercentage not specifiedCode FNoTRUSTEE12/2025Schedule BPDF page 546
29SHINRAI SPECIAL PURPOSE TRUST IMEMBERDomestic entitySHINRAI PTC LLC75% or moreCode ENoMEMBER01/2020Schedule BPDF page 546
30WILLOW STREET TRUST COMPANY OF WYOMING LLCTRUSTEEDomestic entitySHINRAI SPECIAL PURPOSE TRUST IPercentage not specifiedCode FNoTRUSTEE03/2025Schedule BPDF page 546
31SUNFLOWER PTC LLCTRUSTEEDomestic entitySUNBURST TRUSTPercentage not specifiedCode FNoTRUSTEE01/2020Schedule BPDF page 546
32JOHN ALBERT OVERDECKCO-CHAIRMAN; EXECUTIVE MANAGERIndividualTWO SIGMA MANAGEMENT, LLCPercentage not specifiedCode FYesCO-CHAIRMAN; EXECUTIVE MANAGER09/2024Schedule BPDF page 546
33DAVID MARK SIEGELCO-CHAIRMANIndividualTWO SIGMA MANAGEMENT, LLCPercentage not specifiedCode FYesCO-CHAIRMAN09/2024Schedule BPDF page 546
34SETH PHILLIP PLATTEXECUTIVE MANAGERIndividualTWO SIGMA MANAGEMENT, LLCPercentage not specifiedCode FYesEXECUTIVE MANAGER03/2026Schedule BPDF page 546
35THOMAS GERARD RAFFERTYTRUSTEEIndividualDAVID M. SIEGEL REVOCABLE TRUSTPercentage not specifiedCode FNoTRUSTEE02/2026Schedule BPDF page 546

Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.

Compliance & Disclosures

Filing dated 3/31/2026 9:22:06 PM

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that one or more events below involve the firm or its supervised persons.RIA responseYes
AFelonies2 No

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?No
  • A2Been charged with a felony?No
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions3 Yes2 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?No
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions5 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions1 Yes3 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 2 source blocks

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

regulatory · block 1PDF pages 547–549
Regulator name — filed text
CHICAGO BOARD OF TRADE
Monetary/Fine Amount — filed text
$ 25,000.00
How was matter resolved — filed text
Settled

Action status / disposition — filed text

ON FEBRUARY 22 AND 23 2016, FUNDS MANAGED BY TSI AND ITS AFFILIATE, HELD AGGREGATED WHEAT FUTURES POSITIONS IN EXCESS OF THE STANDARD ALL MONTH LIMIT UNDER CHICAGO BOARD OF TRADE RULE 562. ON MARCH 28, 2017, A PANEL OF THE CHICAGO BOARD OF TRADE'S BUSINESS CONDUCT COMMITTEE ACCEPTED TSI'S OFFER OF SETTLEMENT PURSUANT TO WHICH TSI AGREED TO PAY A FINE IN THE AMOUNT OF $25,000 WHILE NEITHER ADMITTING NOR DENYING ANY RULE VIOLATION.
Other filed details

Description of allegations — filed text

ON FEBRUARY 22 AND 23 2016, FUNDS MANAGED BY TWO SIGMA INVESTMENTS, LP ("TSI") AND ITS AFFILIATE HELD AGGREGATED WHEAT FUTURES POSITIONS IN EXCESS OF THE STANDARD ALL MONTH LIMIT UNDER CHICAGO BOARD OF TRADE RULE 562.

Sanction detail — filed text

MONETARY PENALTY ORDERED OF $25,000 WHICH WAS PAID ON MARCH 30, 2017
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CHICAGO BOARD OF TRADE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/22/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CBOT 16-0384-BC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON FEBRUARY 22 AND 23 2016, FUNDS MANAGED BY TWO SIGMA INVESTMENTS, LP ("TSI") AND ITS AFFILIATE HELD AGGREGATED WHEAT FUTURES
POSITIONS IN EXCESS OF THE STANDARD ALL MONTH LIMIT UNDER CHICAGO BOARD OF TRADE RULE 562.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
03/30/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 25,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution

 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
MONETARY PENALTY ORDERED OF $25,000 WHICH WAS PAID ON MARCH 30, 2017
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON FEBRUARY 22 AND 23 2016, FUNDS MANAGED BY TSI AND ITS AFFILIATE, HELD AGGREGATED WHEAT FUTURES POSITIONS IN EXCESS OF THE
STANDARD ALL MONTH LIMIT UNDER CHICAGO BOARD OF TRADE RULE 562. ON MARCH 28, 2017, A PANEL OF THE CHICAGO BOARD OF TRADE'S
BUSINESS CONDUCT COMMITTEE ACCEPTED TSI'S OFFER OF SETTLEMENT PURSUANT TO WHICH TSI AGREED TO PAY A FINE IN THE AMOUNT OF
$25,000 WHILE NEITHER ADMITTING NOR DENYING ANY RULE VIOLATION.
regulatory · block 2PDF pages 549–551
Regulator name — filed text
THE SECURITIES AND EXCHANGE COMMISSION
Monetary/Fine Amount — filed text
$ 45,000,000.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

ON JANUARY 16, 2025, THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ENTERED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND- DESIST PROCEEDINGS (THE "SEC ORDER") AGAINST TWO SIGMA INVESTMENTS, LP AND TWO SIGMA ADVISERS, LP (COLLECTIVELY, "TWO SIGMA") PURSUANT TO SECTION 21C OF THE SECURITIES EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 (THE "ADVISERS ACT"). TWO SIGMA CONSENTED TO THE SEC ORDER WITHOUT ADMITTING OR DENYING THE FINDINGS THEREIN. THE SEC ORDER ALLEGES THAT TWO SIGMA FAILED TO EXERCISE REASONABLE CARE IN ADDRESSING KNOWN MATERIAL VULNERABILITIES TO A SUBSET OF ITS COMPUTER-BASED ALGORITHMIC INVESTMENT MODELS IN BREACH OF ITS FIDUCIARY DUTY OF CARE, HAD DEFICIENCIES IN ITS WRITTEN COMPLIANCE POLICIES AND PROCEDURES, AND FAILED TO REASONABLY SUPERVISE ONE OF ITS MODELERS WHO INTENTIONALLY VIOLATED TWO SIGMA'S POLICIES. SEPARATELY, THE ORDER ALLEGED THAT TWO SIGMA VIOLATED THE SEC'S WHISTLEBLOWER PROTECTION RULE. THE SEC ORDERED THAT TWO SIGMA CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULE 21F-17(A) UNDER THE EXCHANGE ACT AND SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. ADDITIONALLY, THE SEC ORDERED THAT TWO SIGMA BE CENSURED AND EACH OF TWO SIGMA INVESTMENTS, LP AND TWO SIGMA ADVISERS, LP PAY A CIVIL MONEY PENALTY OF $45,000,000 TO THE SEC WITHIN 10 DAYS OF THE ENTRY OF THE ORDER.
Other filed details

Description of allegations — filed text

THE SEC ORDER ALLEGED THAT TWO SIGMA INVESTMENTS, LP ("TWO SIGMA") FAILED TO EXERCISE REASONABLE CARE IN ADDRESSING KNOWN MATERIAL VULNERABILITIES TO A SUBSET OF ITS COMPUTER-BASED ALGORITHMIC INVESTMENT MODELS IN BREACH OF ITS FIDUCIARY DUTY OF CARE, HAD DEFICIENCIES IN ITS WRITTEN COMPLIANCE POLICIES AND PROCEDURES, AND FAILED TO REASONABLY SUPERVISE ONE OF ITS MODELERS WHO INTENTIONALLY VIOLATED TWO SIGMA'S POLICIES. SEPARATELY, THE ORDER ALLEGED THAT TWO SIGMA VIOLATED THE SEC'S WHISTLEBLOWER PROTECTION RULE.

Sanction detail — filed text

MONETARY PENALTY ORDERED OF $45,000,000.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
THE SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST; CENSURE
3.
Date Initiated (MM/DD/YYYY): 
01/16/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
RELEASE NO. 2025-15
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
PRIVATE FUNDS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ORDER ALLEGED THAT TWO SIGMA INVESTMENTS, LP ("TWO SIGMA") FAILED TO EXERCISE REASONABLE CARE IN ADDRESSING KNOWN
MATERIAL VULNERABILITIES TO A SUBSET OF ITS COMPUTER-BASED ALGORITHMIC INVESTMENT MODELS IN BREACH OF ITS FIDUCIARY DUTY OF CARE,
HAD DEFICIENCIES IN ITS WRITTEN COMPLIANCE POLICIES AND PROCEDURES, AND FAILED TO REASONABLY SUPERVISE ONE OF ITS MODELERS WHO
INTENTIONALLY VIOLATED TWO SIGMA'S POLICIES. SEPARATELY, THE ORDER ALLEGED THAT TWO SIGMA VIOLATED THE SEC'S WHISTLEBLOWER
PROTECTION RULE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
01/16/2025
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 45,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
MONETARY PENALTY ORDERED OF $45,000,000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response

must fit within the space provided).
ON JANUARY 16, 2025, THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ENTERED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-
DESIST PROCEEDINGS (THE "SEC ORDER") AGAINST TWO SIGMA INVESTMENTS, LP AND TWO SIGMA ADVISERS, LP (COLLECTIVELY, "TWO SIGMA")
PURSUANT TO SECTION 21C OF THE SECURITIES EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE
INVESTMENT ADVISERS ACT OF 1940 (THE "ADVISERS ACT"). TWO SIGMA CONSENTED TO THE SEC ORDER WITHOUT ADMITTING OR DENYING THE
FINDINGS THEREIN. THE SEC ORDER ALLEGES THAT TWO SIGMA FAILED TO EXERCISE REASONABLE CARE IN ADDRESSING KNOWN MATERIAL
VULNERABILITIES TO A SUBSET OF ITS COMPUTER-BASED ALGORITHMIC INVESTMENT MODELS IN BREACH OF ITS FIDUCIARY DUTY OF CARE, HAD
DEFICIENCIES IN ITS WRITTEN COMPLIANCE POLICIES AND PROCEDURES, AND FAILED TO REASONABLY SUPERVISE ONE OF ITS MODELERS WHO
INTENTIONALLY VIOLATED TWO SIGMA'S POLICIES. SEPARATELY, THE ORDER ALLEGED THAT TWO SIGMA VIOLATED THE SEC'S WHISTLEBLOWER
PROTECTION RULE. THE SEC ORDERED THAT TWO SIGMA CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE
VIOLATIONS OF RULE 21F-17(A) UNDER THE EXCHANGE ACT AND SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7
PROMULGATED THEREUNDER. ADDITIONALLY, THE SEC ORDERED THAT TWO SIGMA BE CENSURED AND EACH OF TWO SIGMA INVESTMENTS, LP AND
TWO SIGMA ADVISERS, LP PAY A CIVIL MONEY PENALTY OF $45,000,000 TO THE SEC WITHIN 10 DAYS OF THE ENTRY OF THE ORDER.

* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.